The National Park Service (NPS) is seeking public comments on its proposal to standardize commercial use authorization (CUA) requirements for road-based commercial tour operators (RBCT), including moving the CUA application and reporting process to an online system for 2025 and a systemwide CUA requirement in 2026. The comment period ends this Saturday, August 10.
IITA encourages members to submit comments on the NPS plan. Read on for IITA’s position and comments.
The National Park Service has been working closely with IITA and allied associations on the plan for RBCT CUAs, since the previously proposed plan was put on hold in 2020. NPS officials have taken heed of the industry’s input to better understand how the travel and tourism industry works, particularly for group tours.
On its Planning, Environment & Public Comment (PEPC), NPS has posted the plan, FAQs and a video demonstrating how the site works. Following is a quick overview.
The RBCT CUA plan has two phases:
- For the 2025 season, RBCT CUA applicants will use the new centralized, online CUA application and reporting system for the parks that have historically issued RBCT CUAs.
While RBCT operators will apply separately for each park in which they need a CUA, the online system will streamline the process allowing an applicant to create a user profile and upload required documentation, saving them from having to do so for each RBCT CUA application. The user profile will securely store that information and incorporate it into each application.
- For 2026, operators will be required to secure RBCT CUAs for nearly every park system wide using the online application system.
Noting there has been confusion about who is responsible for getting the RBCT CUA, NPS says it’s the business entity that assumes the responsibility and liability of the clients traveling in the park, which is typically the tour operator.
RBCT CUA holders must provide proof of a commercial general liability insurance policy in the amount of $500,000 per occurrence and will be accountable for ensuring the vehicles used meet all legal and regulatory requirements.
NPS will standardize the CUA application fee for consistency across the park system. In 2026, the fee per park will be $350.
IITA Position
While IITA has participated in shaping the application process and requirements for these CUAs, its comments in response to the Public Comment period will focus on the $350 per park fee.
IITA leadership has proposed (and will emphasize in its response) a pricing strategy that provides rate reductions based on the number of CUAs operators need. There are a number of unintended consequences with a flat rate for each park.
One such consequence is that a steep fee for every park may be cost-prohibitive for some operators, thus discouraging the inclusion of new park destinations. A typical group tour of the West, for example, visits at least five national parks, which would cost $1,750 in fees alone, resulting in a significant per-person cost increase. Particularly, it may make it impossible for smaller operators that don’t have a volume of tours to the parks to compete with larger companies that can amortize the fees across many more tours.
Additionally, the high cost may result in tour operators not adding new, lesser-known parks, which would help spread the visitation from the most popular and crowded iconic parks for better visitor experiences. Effectively dispersing visitors from overcrowded areas is not only a goal of the industry but also of the National Park Service and the National Travel and Tourism Office’s National Travel and Tourism Strategy. Tour operators can help manage the visitation with the right rate structure.
Inbound operators are encouraged to submit comments to the National Park Service addressing these issues and others that may impact your business.
IITA's Position on National Parks CUA Fees
IITA encourages members to submit comments on the NPS plan. Read on for IITA’s position and comments.
The National Park Service has been working closely with IITA and allied associations on the plan for RBCT CUAs, since the previously proposed plan was put on hold in 2020. NPS officials have taken heed of the industry’s input to better understand how the travel and tourism industry works, particularly for group tours.
On its Planning, Environment & Public Comment (PEPC), NPS has posted the plan, FAQs and a video demonstrating how the site works. Following is a quick overview.
The RBCT CUA plan has two phases:
While RBCT operators will apply separately for each park in which they need a CUA, the online system will streamline the process allowing an applicant to create a user profile and upload required documentation, saving them from having to do so for each RBCT CUA application. The user profile will securely store that information and incorporate it into each application.
Noting there has been confusion about who is responsible for getting the RBCT CUA, NPS says it’s the business entity that assumes the responsibility and liability of the clients traveling in the park, which is typically the tour operator.
RBCT CUA holders must provide proof of a commercial general liability insurance policy in the amount of $500,000 per occurrence and will be accountable for ensuring the vehicles used meet all legal and regulatory requirements.
NPS will standardize the CUA application fee for consistency across the park system. In 2026, the fee per park will be $350.
IITA Position
While IITA has participated in shaping the application process and requirements for these CUAs, its comments in response to the Public Comment period will focus on the $350 per park fee.
IITA leadership has proposed (and will emphasize in its response) a pricing strategy that provides rate reductions based on the number of CUAs operators need. There are a number of unintended consequences with a flat rate for each park.
One such consequence is that a steep fee for every park may be cost-prohibitive for some operators, thus discouraging the inclusion of new park destinations. A typical group tour of the West, for example, visits at least five national parks, which would cost $1,750 in fees alone, resulting in a significant per-person cost increase. Particularly, it may make it impossible for smaller operators that don’t have a volume of tours to the parks to compete with larger companies that can amortize the fees across many more tours.
Additionally, the high cost may result in tour operators not adding new, lesser-known parks, which would help spread the visitation from the most popular and crowded iconic parks for better visitor experiences. Effectively dispersing visitors from overcrowded areas is not only a goal of the industry but also of the National Park Service and the National Travel and Tourism Office’s National Travel and Tourism Strategy. Tour operators can help manage the visitation with the right rate structure.
Inbound operators are encouraged to submit comments to the National Park Service addressing these issues and others that may impact your business.
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